CNPS Response Letter
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California Native Plant Society P.O. Box 1346, Ojai, California 93024-1346 * E-mail: [email protected] 805/646-6045 Voice * 805/646-6975 FAX 16 April 2002 Dennis Hawkins Ventura County Planning Department 800 South Victoria Avenue, L#1740 Ventura, CA 93008 Subject: Comments on Botanical Resources Section of Ahmanson Ranch Development DSEIR Dear Mr. Hawkins: The California Native Plant Society (CNPS) has reviewed the biological resources section of the Draft Supplemental Environmental Impact Report (DSEIR) of the Ahmanson Ranch Phase “A” Tract Map. Below please find specific comments on aspects of the DSEIR that we believe are inadequate or where conclusions and proposed mitigation measures are faulty, impractical, or not supported by the evidence or by sound science. Our comments are organized generally according to resource issue, with page number citations where appropriate, to facilitate focused discussion on the issue addressed, or not addressed, in the DSEIR. CNPS also includes comments on wildlife, as wildlife species are a critical component of the natural vegetation. Without the wildlife species (including invertebrates, amphibians, reptiles, birds, and mammals), many plants would not survive, as they are dependent on wildlife for various functions during at least a part of their life cycles. Some plants depend on invertebrates for fertilization. Some plants depend on animals to disperse their propagules. Some plants indirectly benefit from activities of animals by the localized changes in the soil that the animals make, such as loosening the soil by digging or burrowing. An ecosystem cannot survive without all of its parts, and plants and wildlife depend upon each other directly or indirectly; therefore, CNPS has determined it necessary to expand its comments on projects, such as the Ahmanson Ranch development, to include wildlife. NONVASCULAR PLANTS NOT ASSESSED Even though nonvascular plants (lichens and bryophytes [mosses and liverworts]) are important components of the biological resources and biodiversity of Ventura County and the Ahmanson Ranch project site, these resources were ignored completely in the DSEIR. Comments on both groups of nonvascular plants are provided in the following paragraphs. No Assessment of Lichen Flora Lichens are part of the botanical resources of the State of California, County of Ventura, and City of Simi Valley. A number of lichens are expected to occur at the project site, and some of them may be special- status species. Special-status lichen species are listed by the California Lichen Society1 (CALS) and can 1 Magney, D.L. 1999. Preliminary List of Rare California Lichens. California Lichen Society Bulletin 6(2):22-27. E:\CNPS\Conservation\Ahmanson\CNPS-AhmansonDSEIR-comment_letter.doc Dennis Hawkins, Ventura County Planning CNPS Comments on Ahmanson Ranch DSEIR 4/16/02 Page 2 CNPS be viewed on CALS’s web page (http://ucjeps.herb.berkeley.edu/rlmoe/cals.html or directly to http://128.32.109.44/red.html). The CALS list is very conservative, and many more rare lichen species are likely present, and will be added to the rare lichen list in the future. The DSEIR failed to assess any impacts on lichens. The DSEIR and supporting documents have failed to demonstrate that any field surveys for lichens have ever been conducted in the Ahmanson Ranch development project, much less special-status lichen species. An assessment of project-related impacts on the lichen flora, especially rare lichen taxa, must be conducted as part of the biological resources assessment of the project site. As part of that assessment, indirect impacts to the lichen flora, such as air pollution generation resulting from the project, must be evaluated in addition to direct impacts. Air pollution has caused the loss of lichens in many areas of Southern California, and elsewhere in the developed world. For example, Lace Lichen (Ramalina menziesii) was once common along San Antonio Creek in the Ojai Valley2; however, it has disappeared entirely from the Ojai Valley, likely the result of air pollution. It is entirely possible that Lace Lichen also occurs in the mesic canyons on the Coast Live Oak trees of the project site; however, no evidence has been presented regarding the presence or absence of any species of lichen in the project site. Special-status lichens known to occur in Ventura County include: • Caloplaca ignea • Caloplaca subpyraceella • Cladonia pulvinella • Phaeophyscia kairamoi • Phaeophyscia sciastra • Protoparmelia badia • Punctelia punctilla • Toninia submexicana • Vermilacinia acicularis • Vermilacinia pumila • Vermilacinia robusta • Xanthoparmelia angustiphylla Additional special-status lichen species may occur in Ventura County and at the project site; regardless, no conclusions on this can be made until field surveys for lichens at the Ahmanson Ranch are conducted. For example, two new California species of lichen (Trapeliopsis californica and T. steppica) were recently described (McCune et al. 20023), with only three known populations in the state for T. steppica (one in southern California. Lichens occupy many different habitats, including habitats not occupied by vascular plants. Habitat types likely occupied by lichens at Ahmanson Ranch include: rock (including boulders, bedrock, and cliff faces), soil, and bark (trunks, branches, and twigs of trees and shrubs). Each of these substrates provides habitat to a different sweet of lichen species, with zonation on each substrate based on aspect and exposure. 2 Fry, P. 1999. The Ojai Valley: An Illustrated History. Matilija Press, Ojai, California; Charis Bratt, lichenologist, Santa Barbara Botanic Garden, personal communication, April 2000 regarding Ramalina menziesii historic distribution in Ventura County. 3 McCune, B., F. Camacho, and J. Ponzetti. 2002. Three New Species of Trapeliopsis on Soil in Western North America. The Bryologist 105(1):78-85. E:\CNPS\Conservation\Ahmanson\CNPS-AhmansonDSEIR-comment_letter.doc Dennis Hawkins, Ventura County Planning CNPS Comments on Ahmanson Ranch DSEIR 4/16/02 Page 3 CNPS Field surveys, floristic in nature, need to be conducted for all lichen species present onsite, and an assessment needs to be performed in order to determine if any of the lichens present onsite qualify as special-status species. If any special-status lichen species are found to be present, then feasible mitigation needs to be developed and adopted to compensate for the impacts. Simply preserving existing populations offsite is not sufficient mitigation for onsite project impacts. The EIR fails to meet these basic requirements of CEQA for the lichen flora, and is inadequate. Project-related direct and indirect impacts on the lichen flora from air pollution need to be assessed in the EIR. Some species of lichens are known to be sensitive to air pollution, while others can be good indicators of airborne pollutants since they accumulate some pollutants in their tissues. Ramalina menziesii is a good example of a fruticose-type lichen that is highly sensitive to air pollution, which has been killed off from much of its former range in California where air pollution is concentrated. The Ventura County Superior Court found an EIR prepared for the Camarillo Regional Park amphitheater and golf course proposal to be inadequate (CNPS vs Ventura County Board of Supervisors) in part for its failure to address project-related (direct and indirect) impacts to the lichen flora present at that site. The DSEIR should be revised to include a complete and proper assessment of the lichen flora of the project site and determine if project-related impacts are significant. Simply ignoring this resource is not acceptable under CEQA. One aspect of this case was the County’s failure to assess air pollution impacts on the lichen flora. No Assessment of Bryophyte Flora Bryophytes (mosses and liverworts) are part of the flora; however, no surveys for bryophytes, much less special-status bryophyte species, were conducted for this project. CNPS maintains a list of rare and endangered bryophytes in its Inventory of Rare and Endangered Plants of California (CNPS 20014). This should be consulted, and surveys of the bryophyte flora should be conducted to determine species richness; then a determination as to whether any special-status bryophytes occur onsite, and whether they will be adversely impacted by the proposed project. The DSEIR fails to meet these basic requirements of CEQA for the bryophyte flora, and is inadequate. “Rockland”, as described in the DSEIR, especially on the mesic north-facing slopes of them, is good habitat for bryophytes and lichens. Impacts to habitats supporting bryophytes would eliminate this biological resource; however, this component of the biological resources present at Ahmanson Ranch was never assessed. Field surveys, floristic in nature, need to be conducted for all bryophyte species present onsite, and an assessment needs to be performed to determine if any of the bryophytes present onsite qualify as special- status species. If any special-status bryophyte species are found to be present, then feasible mitigation needs to be developed and adopted to compensate for the impacts. Simply preserving existing populations offsite is not sufficient mitigation for onsite project impacts. The EIR fails to meet these basic requirements of CEQA for the bryophyte flora, and is inadequate. 4 California Native Plant Society. 2001. Inventory of Rare and Endangered Plants of California. Sixth edition. (Special Publication No. 1.) Rare Plant Scientific